December 20, 2024

Cindy Xiaofan Wang
Chief Financial Officer
Trip.com Group Ltd
30 Raffles Place, #29-01
Singapore 048622

       Re: Trip.com Group Ltd
           Form 20-F for Fiscal Year Ended December 31, 2023
           Filed April 29, 2024
           File No. 001-33853
Dear Cindy Xiaofan Wang:

       We have reviewed your filing and have the following comment(s).

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 20-F for Fiscal Year Ended December 31, 2023
General

1.     We note the changes you have made to your disclosure appearing at the
outset of Item
       3, "Key Information" and in your risk factor disclosure relating to the
legal and
       operational risks associated with operating in China and the level of
uncertainty in the
       PRC's legal and regulatory regimes. For example, you have removed
references to
       "substantial" uncertainties with respect to PRC laws and regulations
throughout and
       have revised risk factor disclosure regarding the PRC legal system,
including
       interpretation and enforcement of certain PRC laws and regulations, to
mitigate the
       concept that rules and regulations in China can change quickly with
little advance
       notice. We also note the changes to your risk factor disclosure
regarding cash transfer
       and foreign exchange restrictions by the PRC government. It is unclear
to us that there
       have been changes in the regulatory environment in the PRC since the
filing of your
       annual report on Form 20-F for the fiscal year ended December 31, 2022
(the "2022
       Annual Report"), warranting revised disclosure to mitigate the
challenges you face
       and related disclosures. The Sample Letters to China-Based Companies
sought
       specific disclosure relating to the risk that the PRC government may
intervene in or
 December 20, 2024
Page 2

       influence your operations at any time, or may exert control over
operations of your
       business, which could result in a material change in your operations
and/or the value
       of your securities. The Sample Letters also sought specific disclosures
relating to
       uncertainties regarding the enforcement of laws and that the rules and
regulations in
       China can change quickly with little advance notice. We do not believe
that your
       revised disclosure on these topics convey the same risks. In future
filings, please
       restore your disclosures in these areas to the disclosures as they
existed in the 2022
       Annual Report, updated only for developments specific to your business
or the
       passage of time.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

       Please contact Abe Friedman at 202-551-8298 or Doug Jones at
202-551-3309 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Rebekah Reed at 202-551-5332 or Donald Field at 202-551-3680 with any
other
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Trade &
Services
cc:   Haiping Li